Transferwise Privacy Policy

Dated: 7 February 2018

Transferwise, Inc. is concerned about privacy issues and wants you to be familiar with how we collect,
use and disclose information. This Privacy Policy describes our practices in connection with information that we collect
through our websites from which you are accessing this policy, including www.transferwise.com (the “Websites”), through
the software applications made available by us for use on or through computers and mobile devices (the “Apps”), as well as
through HTML-formatted email messages that we send to you that link to this Privacy Policy (collectively, including
the Websites and Apps, the “Services”). By providing Personal Information to us or using the Services, you agree to
the terms and conditions of this Privacy Policy.

We use information that we collect from or about our customers in accordance with our Consumer Privacy Notice, which provides choices about our sharing and use of information.

Information we may collect about you

We may collect, through the means described here, the following information:

Personal Information you give us. “Personal Information” is information that identifies you as an individual or relates to an identifiable person. We collect your Personal Information when you provide it to us, such as when you register to use our Services, participate in discussion boards or other social media functions on the Services, enter a competition, promotion or survey, report a problem with our Services or otherwise communicate with us. The Personal Information you give us may include your name, address, e-mail address, phone number, financial information (including credit card, debit card, or bank account information), and social security number.

We may also need to collect additional commercial and/or identification information from you, such as if you send or receive certain high-value or high volume transactions or as needed to comply with our anti-money laundering or other obligations under applicable law.

If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Other Information we collect. “Other Information” is information that does not reveal your specific identity or does not directly relate to an individual. We may automatically collect the following information when you use the Services:

Details of the transactions you carry out on when using our Services, including the country from which the transaction originates;

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, Internet browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform;

Information about your use of the Services, including the full Uniform Resource Locators (URL) clickstream to, through and from the Services (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support number.

We may aggregate Personal Information. Such aggregated information does not personally identify you or any other user of the Services. For example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code.

Information we receive from other sources. We work closely with third parties and may receive information about you from them. These third parties may include, for example, banks and payment service providers you use to transfer money to us; banks and payment service providers of your recipient; business partners; sub-contractors in technical, payment and delivery services; advertising networks; analytics providers; search information providers; credit reference agencies; public databases; and social media platforms.

If you log in to our Services using your social media account (for example, Facebook or Google) we will receive relevant information that is necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information that you have provided to them, including your name, profile image and e-mail address. We use such information, together with any other information you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. You may also be able to specifically request that we have access to the contacts in your social media account so that you can send a referral link to your family and friends. We will use, disclose and store all of this information in accordance with this privacy policy.

Cookies and Similar Technologies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience and also allows us to improve our Website. Cookies allow us to collect information such as browser type, time spent on the Website, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Services and to recognize your computer in order to assist your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies to track responses to our online advertisements.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit.

At this time we do not respond to browser do-not-track signals.

Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Services to, among other things, track the actions of users (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.

We may use third-party analytics providers, such as Google Analytics and Mixpanel, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. These third parties may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. You can learn about Mixpanel’s practices and how to opt out of them by going to https://mixpanel.com/terms/.

We may use Adobe Flash Local Shared Objects (“Flash LSOs”) and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including those used in connection with the Services.

Third Party Advertisers

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites, apps or online services, based on information relating to your access to and use of the Services and other websites, apps or online services on any of your devices. To do so, these companies may place or recognize a unique cookie on your browser (including through use of pixel tags). They may also use these technologies, along with information they and we collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/. You may also download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.

Uses made of the information

We may use your Personal Information in the following ways:

to carry out our obligations relating to your contracts and transactions with us and to provide you with the information, products and services that you request from us, as well as related customer service;

to notify you about changes to our Services or to send you other administrative information;

to improve our Services and so that they are presented in the most effective manner;

to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;

to allow you to participate in interactive features of our Services, when you choose to do so;

to facilitate social sharing functionality; and

consistent with choices that may be available to you, to provide you with information about other goods and services we feel may interest you.

We may also use and disclose Personal Information as we believe necessary or appropriate: (a) under any applicable legal and/or regulatory requirements, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) as part of our efforts to keep our Services safe and secure, including to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined.

Disclosure of your information

We may share your Personal Information with selected third parties including:

affiliates, business partners, joint marketers, suppliers and sub-contractors for the performance of any contract we enter into with them or you;

advertisers and advertising networks solely to select and serve relevant advertisements to you and others; and

analytics and search engine providers that assist us in the improvement and optimisation of our site.

Your Personal Information may also be disclosed:

consistent with choices that may be available to you, to our affiliates for the purposes described in this privacy policy;

consistent with choices that may be available to you, to permit selected third parties to provide you with information about goods or services;

by you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public;

to your friends associated with your social media account, to other users of the Services and to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your Services account or log into your Services account from your social media account. By connecting your Services account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy;

in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);

if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our User Agreement and other applicable agreements; or to protect the rights, property, or safety of TransferWise, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;

to assist us in conducting or co-operating in investigations of fraud or other illegal activity, or to respond to requests from public and government authorities (including those outside your country of residence), where we believe it is reasonable and appropriate to do so;

to prevent and detect fraud or crime;

in response to a subpoena, warrant, court order, or as otherwise required by law;

to assess financial and insurance risks, and to protect our operations and those of any of our affiliates;

to allow us to pursue available remedies or limit the damages that we may sustain

to recover debt or in relation to your insolvency; and

to develop customer relationships, services and systems.

Your Choices Regarding our Use of your Personal Information

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the instructions in any such email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out, we may still send you important administrative messages, from which you cannot opt-out.

Third Party Services

Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates, and others. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us. If you follow a link to any of these websites, please note that we are not responsible for the privacy, information or other practices of any of these third parties.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Apple, Google, Microsoft, RIM or any other app developer, app provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps.

How do we protect your personal information

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact” section below.

Access to information

If you would like to review, correct, update, suppress or delete Personal Information that you have previously provided to us, you may contact us at our Customer Support number.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

Use of Services by Minors

The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Information through the Services.

Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

Changes to our Privacy Policy

We may change this Privacy Policy. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes we may make to our Privacy Policy will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@transferwise.com. Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

Facts

WHAT DOES TRANSFERWISE, INC. DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

Social Security number and checking account information

account balances and payment history

transaction history and wire transfer instructions

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons TransferWise, Inc. chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does TransferWise, Inc. share?

Can you limit this sharing?

For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes— to offer our products and services to you

Yes

No

For joint marketing with other financial companies

Yes

No

For our affiliates’ everyday business purposes—information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes—information about your creditworthiness

No

We don’t share

For nonaffiliates to market to you

No

We don’t share

Questions?

Call (888) 908-3833

What we do

How does TransferWise, Inc. protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does TransferWise, Inc. collect my personal information?

We collect your personal information, for example, when you

open an account or give us your contact information

tell us who receives the money or tell us where to send the money

make a wire transfer

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only

sharing for affiliates’ everyday business purposes—information about your creditworthiness

tell us who receives the money or tell us where to send the money

make a wire transfer

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Our affiliates include companies with a TransferWise name; financial companies such as TransferWise Limited and TransferWise Canada Inc.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

ransferWise Inc. does not share with nonaffiliates so they can market to you

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

Our joint marketing partners can include banks

Other Important Information

For California residents:

We will not share information we collect about you with nonaffiliated third parties, except as permitted by law, including, for example, with your consent or to service your account. We will limit sharing with our affiliates to the extent required by California law.

For Vermont residents:

We will not share information we collect about you with nonaffiliated third parties, except as permitted by law, including, for example with your consent or to service your account. We will not share information about your creditworthiness with our affiliates, other than as permitted by Vermont law, unless you authorize us to make those disclosures.